Speak Up
At Practica Capital, we expect high standards of integrity, fairness and professional conduct. If something does not look right, we want to know about it.
Practica Capital Management UAB provides a secure whistleblowing channel for reporting suspected misconduct, breaches of law or regulation, violations of our internal policies, or other serious concerns relating to Practica Capital Management, the funds we manage or their portfolio activities.
The channel is available to current and former employees, members of our governing bodies, job applicants, service providers and contractors, founders and employees of portfolio companies, investors, co-investors and other persons who obtain information about a possible breach in a work-related context.
What can be reported?
You may report actual, attempted or suspected wrongdoing, including:
fraud, theft, corruption or other financial misconduct;
false or misleading financial, operational or KPI reporting;
conflicts of interest, improper benefits or unethical investment conduct;
breaches of AML, KYC, sanctions or other regulatory requirements;
breaches of fund documentation, investment restrictions or internal policies;
unauthorised disclosure of confidential information, data protection or information-security breaches;
harassment, discrimination, bullying or other serious misconduct in Practica Capital Management's own workplace;
serious ESG, environmental, health and safety, competition or other legal breaches; and
retaliation against someone who has raised a concern or attempts to obstruct an investigation.
For portfolio companies, the channel is limited to matters materially affecting a Fund's investment or Practica Capital Management's rights or obligations as investor, such as fraud, material misrepresentation or a breach of shareholder or investment documents; workplace misconduct internal to a portfolio company should be reported through that company's own channels.
The whistleblowing channel is intended for genuine concerns about wrongdoing. It is not intended for ordinary commercial complaints, routine HR matters or interpersonal disputes that do not involve a breach.
Report securely - with or without identifying yourself
Reports can be submitted through an independent third-party reporting platform. You can choose to provide your identity or report anonymously. Anonymous reports are handled with the same diligence as identified reports.
If you choose to report anonymously, you do not need to provide your name or contact details. The platform provides confidential case access credentials that allow you to return to your case, receive questions and updates, and continue communicating without disclosing your identity. Please keep those credentials safe.
The independent platform is intended to support anonymous reporting. Practica Capital does not attempt to identify persons who choose to report anonymously. The confidentiality and anonymity features available to you depend on the reporting method and the platform configuration in force at the time of reporting.
Prefer to contact us directly?
You may also report directly to either of the persons responsible for the whistleblowing process at Practica Capital:
MLRO / Channel Administrator - Kotryna Blažaitytė
kotryna@practica.vc
Risk Officer / Alternate Channel Administrator - Gintas Daniusevičius
gintas@practica.vc
You may choose either recipient and do not need to copy both. Direct email reports are treated confidentially, but email is not an anonymous reporting method because sender details and other technical information may identify you. If you want to remain anonymous, please use the independent reporting platform above.
If your concern involves one of the persons listed above, contact the other person. Where both are conflicted, use the external reporting routes described below.
What happens after you report?
Only authorised, non-conflicted persons may access and handle a report. A person implicated in a report or otherwise conflicted will not handle the case or have access to the case file, except where information must lawfully be provided for defence rights.
Where you can be contacted safely, receipt will generally be acknowledged within 7 calendar days. We will assess whether the report falls within scope, whether immediate protective or containment measures are needed, whether it must be referred to a competent authority, and how the matter should be investigated.
We aim to provide feedback on actions envisaged or taken within 3 months of acknowledgement, subject to applicable law. If an investigation is still ongoing, we may provide interim feedback consistent with confidentiality and investigation requirements.
If you report anonymously, please return to the reporting platform periodically using your confidential case credentials. We may need additional information from you in order to investigate effectively.
Confidentiality and protection from retaliation
Reports are treated confidentially. The identity of an identified reporting person, and information that could directly or indirectly reveal that identity, is restricted to authorised persons handling the matter, except where disclosure is required by law.
Practica Capital does not tolerate retaliation against a person who raises a concern on reasonable grounds. This protection also extends, where applicable, to people assisting a reporting person and persons connected to them who could suffer retaliation.
A report made on reasonable grounds remains protected under our internal policy even if the concern is ultimately not substantiated. Formal whistleblower status and statutory protections under Lithuanian law are determined by the competent authority and are subject to the conditions of applicable law.
Other ways to report
A report may also be made in person by arranging a meeting with the MLRO / Channel Administrator or the Risk Officer / Alternate Channel Administrator.
A report may also be sent by post to Practica Capital Management UAB's registered office in a sealed envelope clearly marked:
"Confidential - Whistleblower Report - to be opened by the addressee only."
External reporting
You are not required to report a concern to Practica Capital first. Depending on the nature of the matter, you may report directly to the appropriate competent authority, including the Prosecutor General's Office of the Republic of Lithuania, the Bank of Lithuania, the Financial Crime Investigation Service (FNTT), the State Data Protection Inspectorate or another competent Lithuanian or EU authority.
Practica Capital will not restrict, discourage or penalise a person for making a protected report to a competent authority. Information on reporting to the Prosecutor General's Office and formal whistleblower status is available at www.pranesktiesa.lt.
Our Whistleblower Policy
More information about who may report, how reports are handled, confidentiality, investigations, protection against retaliation and external reporting is available in the Practica Capital Management UAB Whistleblower Policy.
